Linda S. Adams

Secretary for 

Environmental Protection

 

The energy challenge facing California is real. Every Californian needs to take immediate action to reduce energy consumption. 

For a list of simple ways you can reduce demand and cut your energy costs, see our website: http://www.arb.ca.gov

Air Resources Board Mary D. Nichols, Chairman 

9480 Telstar Avenue, Suite 4 

El Monte, California 91731 www.arb.ca.gov Arnold Schwarzenegger

 Governor 

February 24, 2009 

Manufacturers Advisory Correspondence MAC #2009-01 

To: ALL VEHICLE MANUFACTURERS OF PASSENGER CARS, 

LIGHT DUTY TRUCKS, AND MEDIUM-DUTY PASSENGER 

VEHICLES 

Subject: Implementation of the New Environmental Performance Label. 

This letter transmits the enclosed Manufacturers Advisory Correspondence (MAC) 

which outlines the process for implementing the new Environmental Performance (EP) 

label. The MAC discusses the EP label approval process for vehicles produced after 

January 1, 2009, and for vehicles produced prior to that date for which the manufacturer 

is voluntarily applying the EP label. In addition, the MAC discusses the approval 

process for receiving air conditioning (AC) emission reduction credits based on 

AC-direct and AC-indirect system improvements. And finally, the MAC outlines the 

global warming scoring procedure for Medium-Duty Passenger Vehicles certified under 

California’s Cleaner Federal Vehicle rule subject only to FTP testing from which only the 

measured city CO2 values are reported. 

If you have any questions regarding EP label format, please contact Mr. Craig Duehring, 

Air Resources Engineer, ZEV Infrastructure Section, at (916) 323-2361 or by email at 

cduehrin@arb.ca.gov. For approval of credits for improved air conditioning systems, 

please contact Mr. Tao Huai, Manager, Climate Change Mitigation and Emission

Research Section, at (916) 324-2981 or by email at thuai@arb.ca.gov. For EP label 

score matters, please contact Ms. Rhonda Runyon, Air Pollution Specialist, On-Road 

Certification / Audit Section, at (626) 575-6653 or by email at rrunyon@arb.ca.gov. 

Sincerely, 

/s/ 

Annette Hebert, Chief 

Mobile Source Operations Division 

Attachment 

. 

California Environmental Protection Agency

Printed on Recycled Paper
1

State of California 

AIR RESOURCES BOARD 

MANUFACTURERS ADVISORY CORRESPONDENCE (MAC) 2009-01 

SUBJECT: Implementation of the new Environmental Performance Label. 

APPLICABILITY: All 2009 and subsequent model year passenger cars, light-duty 

trucks and medium-duty passenger vehicles produced on or after 

January 1, 2009, including those produced by small and 

intermediate volume manufacturers. 

The global warming scores (GWS) discussed in this MAC are 

determined pursuant to section 3(a)(2) of the California 

Environmental Performance Label Specifications. Upon California 

receiving the federal waiver, the GWS will be determined based on 

the requirements in 13 CCR 1961.1; additional guidance will be 

issued as needed. 

REFERENCES: Title 13, California Code of Regulations (CCR), Section 1965 and 

“California Environmental Performance Label Specifications For 

2009 And Subsequent Model Year Passenger Cars, Light-Duty 

Trucks, And Medium-Duty Passenger Vehicles” Adopted: May 2, 

2008 

Mailout MSO# 2007-03 “New Requirement to Report Carbon 

Dioxide Emissions from 2008 and Subsequent Model Year 

California Certified Vehicles and Engines” 

BACKGROUND: Currently, all vehicle manufacturers are prohibited from selling a 

passenger car or light duty vehicle lacking a Smog Index label 

affixed for display at the point of sale. For vehicles produced on or 

after January 1, 2009, the manufacturers are required to replace 

the Smog Index label with the new Environmental Performance 

(EP) label which includes both a Smog and Global Warming score. 

The new regulation allows for early implementation to 

accommodate a smooth transition for replacing the Smog Index 

label with the new EP label. This transition period ends on 

January 1, 2009 when only the new EP label will be displayed on 

each new vehicle. The regulation requires manufacturers to submit 

labels to the ARB for review and approval prior to display of the 

new EP label. Since the majority of 2009 model year test groups 

are already certified, this MAC describes the approval process for 

2009 model year test groups already certified and the approval 
2

process for pending 2009 and subsequent model year applications. 

Both scenarios are discussed below. 

In addition, this MAC will discuss the application and approval 

process for receiving air conditioning (AC) emission reduction 

credits based on AC-direct and AC-indirect system improvements. 

Finally, this MAC outlines the global warming scoring procedure for 

Medium-Duty Passenger Vehicles certified under California’s 

Cleaner Federal Vehicle rule subject only to FTP testing, from 

which only the measured city CO2 values are reported. 

PROCESS: Approval of New Environmental Performance Label

A request for approval must contain the following two parts: 

1. A sample EP label to evaluate the format in accordance with the 

regulations. And, 

2. The data necessary to determine the Smog and Global Warming 

scores. 

A request for approval of the EP label format and the request to 

approve smog and global warming scores may be made under 

separate cover. 

Requests for label format approval shall be submitted to: 

Craig Duehring 

Mobile Source Control Division 

1001 I Street, P.O. Box 2815 

Sacramento, CA 95812 

Email: cduerhin@arb.ca.gov 

Requests for smog and global warming score approval shall be 

submitted to the On-Road Certification / Audit Section via the 

ARB’s Document Management System (DMS). Manufacturers 

shall submit their request to the following folder within their DMS 

directory: 

 \\ARB MFR code – Manufacturer Name\PC-LDT\2009\CBI 

APPLICATION\CORRESPONDENCE\MISCELLANEOUS 

Manufacturers shall give their request the following file name: 

CBI_9MFR_CORRESP_RFA*LAB_ where MFR is the U.S. EPA 

manufacturers code. 
3

For 2009 model year test groups which are certified as of the date 

of this MAC, manufacturers shall submit one request for approval of 

their sample label and smog and global warming scores for all

certified 2009 model vehicles. 

For pending 2009 model year applications and 2010 and 

subsequent model year applications, manufacturers shall submit 

sample labels for format approval and the data necessary to 

determine the smog and global warming scores for the vehicle 

models within their test group application. Manufacturers shall 

submit the data necessary for score approval in the format 

attachment to this MAC. 

For 2009 model year vehicles manufactured prior to 

January 1, 2009, manufacturers may affix an approved EP label to 

vehicles in any of the following manners: (i) the EP label in lieu of 

the Smog Index label; (ii) the EP label overlaying the Smog Index 

label; or (iii) the EP label in the proximity of the Smog Index label. 

All 2009 model year vehicles manufactured on or after 

January 1, 2009 must display only the new EP label. 

The information necessary for approval of both the label format and 

the label scores are described below. 

 Label Format Approval

Prior to displaying the new EP label on any vehicle, the 

manufacturer must submit a sample label to the person identified 

above for format review and approval. Only one sample label per 

manufacturer is required for format and size approval. However, if 

a manufacturer uses both the standard 4 x 6 inch label and the 

reduced 21⁄2 x 41⁄2 inch label, ARB will require samples of both label 

formats for approval. Staff will be looking for label color, size, font, 

style and overall specification compliance. 

If the new EP label will be placed on label feedstock that contains 

other vehicle information, the sample label must include the other 

vehicle information to be displayed. If the manufacturer will be 

placing the new EP label within the vehicle’s Monroney Sticker, 

staff will require a sample of the entire Monroney sticker with the 

new EP label displayed. Finally, if a sample label is not 

immediately available due to feedstock ordering lead time, staff will 

accept a .pdf file of the proposed label for review and temporary 

approval. However, once the feedstock is available with the new 

label format, the manufacturer must submit a sample label to staff 

for final approval. 
4

Annual approval of label format is not required. However, ARB 

may require submission of sample labels periodically for 

compliance purposes. Staff will contact the manufacturer if 

additional sample labels are required. 

 Smog and Global Warming Score Approval 

In order to receive approval of the smog and global warming scores 

the following information shall be submitted. This information shall 

be submitted in the attached format by test group. 

For Each Test Group:

• Models within the test group 

• Emissions standard category 

• The smog score 

• CO2 city and CO2 highway values as reported in accordance 

with the August 29, 2007, ARB Mailout, MSO #2007-03 

• Fuel adjustment factor 

• Approved AC-direct and AC-indirect credit values 

• CO2-equivalent combined value 

• The global warming score 

As mentioned above for 2009 model year test groups already 

certified, this information may be submitted for all test groups in a 

single request. For pending 2009 applications and 2010 model 

year applications, this information shall be included in each 

manufacturer’s test group specific application for certification. As 

mentioned above, submit requests via the ARB’s DMS. Please 

submit the data in the excel format prescribed in the attachment to 

this MAC. 

A/C CREDITS: Emission Reduction Credits for Improved Air Conditioning 

(A/C) Systems

In accordance with section 3.(a)(2) of the “California Environmental 

Performance Label Specifications For 2009 And Subsequent Model 

Year Passenger Cars, Light-Duty Trucks, And Medium-Duty 

Passenger Vehicles.” adopted May 2, 2008, vehicle manufacturers 

may submit applications for ARB approval to determine A/C-direct 

and A/C-indirect emission reduction credits for A/C systems 

designed to reduce the amount of greenhouse gas emissions from 

A/C operation and leakage. Applications for emission reduction 

credits for improved A/C systems must be submitted separately 

from other approval requests and must be applicable to all vehicles 

identified in each test group. Applications for A/C credits must 

clearly indicate that the A/C system emissions data submitted 
5

applies to all vehicles within the specified test group. If the A/C 

system emissions data does not apply to all vehicles within the test 

group, then no A/C credits will be earned for that test group. 

In general, the regulatory equation used to calculate the global 

warming score of the vehicle assigns default values for the 

increased greenhouse gases emitted when using a typical air 

conditioner with HFC-134a as the refrigerant. These default 

values, six grams carbon dioxide equivalents (CO2e)/mile for A/Cdirect and 17 grams CO2e/mile for A/C-indirect are inherently 

conservative since they represent the nominal level of emissions 

expected for a range of vehicles and systems. They are based on 

prior research and emissions modeling. 

Applications to receive A/C-direct and A/C-indirect emission 

reduction credits must provide an engineering analysis with 

laboratory results clearly showing the technical and design 

advances that will yield reductions to these default values. The 

application must also contain descriptions of 

component-by-component modifications made to achieve increased 

refrigerant containment and system efficiencies. All applications for 

A/C emission reduction credits must provide actual certification test 

data to support the results submitted and must clearly show all 

improvements made to achieve these results. In addition, the 

Executive Officer retains the right to ask for additional information 

as part of this application process. 

The regulatory language provides the minimum application 

submission requirements to support claims for A/C improvements. 

These submission requirements are repeated and further clarified 

below for convenience. 

Requests shall be submitted to: 

Tao Huai, Manager 

Climate Change Mitigation and Emissions Research Section 

Research Division 

1001 I Street, P.O. Box 2815 

Sacramento, CA 95812 

(916) 324-2981 

Email: thuai@arb.ca.gov 

Craig Duehring 

Mobile Source Control Division 

1001 I Street, P.O. Box 2815 

Sacramento, CA 95812 

(916) 323-2361 

Email: cduehrin@arb.ca.gov 
6

 

A/C DIRECT: A/C-Direct Emission Reduction Credits

For A/C-direct emission improvements in systems using HFC-134a 

as the refrigerant, the manufacturer must demonstrate and submit 

for approval the following: 

1. The manufacturer must demonstrate via engineering evaluation 

that the A/C system minimizes overall refrigerant leakage by: 

a. Minimizing the number of or improving fittings and joints. 

b. Limiting the use of single O-rings for pipe and hose 

connections. 

c. Using lowest permeability hose for containment of the 

refrigerant. 

d. Minimizing leakage from compressor shaft seal and housing 

seals. 

Based on the above regulatory language, staff is requesting the 

following information: 

• Specify (types, numbers, lengths, hose permeability and the 

permeability test procedures employed, etc) the A/C system 

components that contribute to refrigerant leakage in the system in 

question. Provide sufficient specifications for the system in 

question to enable replication of the system refrigerant emissions 

calculation using SAE International Standard J2727. Attach the 

calculation spreadsheet based on SAE J2727 spreadsheet 

template. 

• Provide illustrations or pictures of the placement of components in 

the system in question. 

• Provide description of design changes and explain how the 

number of fittings and joints has been minimized relative to a 

previous design/system. 

• Justification of the use of single O-rings to qualify as a “low-leak” 

system, as applicable. 

• Justification of the use of hose if lowest permeability hose (ultralow permeability barrier or veneer hose) is not used to qualify as a 

“low leak” system, as applicable. 

• Explain how leakage from the compressor shaft seal and housing 

seals has been minimized. 
7

If other improvements not reflected in SAE J2727 Standard are made 

to the system in question, the manufacturer is encouraged to provide 

other relevant information to ARB as part of the application. 

ARB is continually exploring how demonstration of leakage 

determination via SAE J2727 can be enhanced. Results from miniSHED leak testing, results quantifying production line mis-assembly 

rates, and any related information manufacturers wish to include in 

the application package would be very useful. 

2. Annual leakage refrigerant emissions as tested and measured 

in accordance with SAE International standard J2727 indicating 

a measured annual refrigerant leakage of less than 55 grams. 

Although the regulation specifies the July 2007 revision of SAE 

J2727, staff will accept data using the latest revision available. 

Each application must provide the leakage rate used to 

calculate A/C-direct emission credits as determined using the 

SAE J2727 calculation. In addition, each application must 

provide sufficient information for staff to replicate the SAE J2727 

calculation for the system in question. 

If the A/C system is determined to be a “low-leak” system in 

accordance with paragraphs 1 and 2 above and if approved by 

ARB, the A/C-direct emission reduction credit will then be 

calculated using the following equation: 

A/C-direct emission reduction credit = 6 – (SAE J2727 measured 

annual refrigerant leakage in grams) x 1,300 / 12,000 

All applications requesting A/C-direct emission reduction credits 

must demonstrate they comply with the requirements and 

improvements identified in paragraphs 1 and 2 above. 

For A/C systems using a refrigerant with a global warming potential 

of less than or equal to 150 times that of CO2, the global warming 

potential from refrigerant leakage is considerably less than other 

annual greenhouse gas emissions and the manufacturer will get the 

maximum A/C-direct emission reduction credit of six grams 

CO2e/mile. 

A/C INDIRECT: A/C-Indirect Emission Reduction Credit

A/C-indirect emission reductions can be achieved if the A/C system 

is designed to be an “improved” system. To qualify as an 

“improved” system that uses CO2, HFC-134a, HFC-152a, or other 

halocarbon refrigerant, the following requirements apply and the 

Executive Officer will review submitted demonstrations for approval: 
8

1. The manufacturer must demonstrate using test data in an 

engineering evaluation that the A/C system achieves lower A/Cindirect emissions than the default value of 17 grams CO2e/mile. 

The engineering evaluation in the application package should 

include CO2 vehicle test emissions data for operation without A/C 

(FTP) and with A/C (SFTP: SC03 test cycle conducted under test 

conditions described in 40 CFR 86.158 and related sections) as a 

means for determining indirect A/C emissions. The manufacturer 

must submit CO2 emissions results from these tests for the test 

group which the application for A/C credits applies. The eligibility of 

A/C-indirect credit is determined from the FTP and SC03 CO2

measured emission rates as follows: 

The system qualifies if: 

[(SC03CO2 ― 112) / (0.954 × FTPCO2) × 17] < 17.0 g/mi 

The system does not qualify if: 

[(SC03CO2 ― 112) / (0.954 × FTPCO2) × 17] ≥ 17.0 g/mi 

The default value of 17 g/mi represents the difference between FTP 

with A/C operation and FTP without A/C operation, and is adjusted 

for the average fraction of time a vehicle’s A/C system is on in 

California. Existing certification test procedures do not include an 

FTP test cycle with A/C operation, but they do include an SC03 test 

cycle with A/C operation under specified conditions of temperature, 

humidity, and solar load. In order to avoid the need for additional 

testing, ARB will rely on data from existing certification test results 

to demonstrate A/C-indirect impacts. 

For dedicated alternative-fueled vehicles (AFVs), which are not 

subject to SFTP testing, two options are available with prior ARB 

approval. Manufacturers may test the official certification test 

vehicle under the SC03 test procedure to determine the SC03 

CO2-equivalent value. Or, manufacturers may provide an 

engineering evaluation comparing the A/C system on the AFV to an 

identical or similar A/C system on an identical or similar gasoline or 

diesel vehicle and determining the CO2-equivalent emission 

reduction due to A/C system improvements. 

A/C-indirect impacts are shown in Table 1. CO2 emissions are 

higher during the SC03 than during the FTP, partly due to the A/C 

and partly due to cycle effects. The overall relationship is shown in 

Figure 1. This regression line is used to represent default values for 

the purpose of demonstrating improvements. A vehicle having a 

reduced contribution of A/C to CO2 emissions will fall below this 

line, and will be considered to have demonstrated improved A/C 

system performance. 
9

Table 1: Emissions Measured under FTP and SC03 Test Procedures 

Vehicle 

ID 

Vehicle 

Class 

FTP with no 

A/C 

SC03 with 

A/C 

1 Small Car 269.2 369.2

2 Midsize Car 342.4 452.7

3 Midsize Car 440.2 529.5

4 Large Car 454.3 548.7

5 Small Car 335.8 441.2

6 Midsize Car 388.8 488.8

7 Large Van 942.6 1021.9

8 Minivan 440.4 551.4

9 Small SUV 521.5 592.0

10 Minivan 468.6 519.6

11 Minivan 488.3 599.9

12 Large SUV 690.3 789.7

13 Van 696.0 758.1

14 Large Truck 543.6 615.5

15 Midsize Car 427.7 508.5

y = 0.954x + 112

R2

 = 0.989

300

400

500

600

700

800

900

1000

1100

200 300 400 500 600 700 800 900 1000

FTP CO2 (g/mi)

SC03 CO2 (g/mi)

Figure 1: Correlation between Emissions Measured under FTP and SC03 
10

2. The system must manage outside and re-circulated air balance 

to achieve comfort, demisting, and safety requirements, based 

on factors such as temperature, humidity, pressure, and level of 

fresh air in the passenger compartment in order to minimize 

compressor usage. 

3. The system must be optimized for energy efficiency by utilizing 

state-of-the-art high efficiency evaporators, expansion devices, 

condensers, and other components. 

4. The system must have external controls that adjust the 

evaporative temperature to minimize the necessity of reheating 

cold air to satisfy occupant comfort. 

Each application must provide information about the configurations 

of the A/C system, including, but not limited to, the types, sizes and 

features of each major component. Explain how the system has 

been designed so that it meets the above criteria 2 through 4. 

An internally controlled A/C system could also qualify as an 

“improved” system as long as the manufacturer demonstrates that 

the system achieves the same goal as minimizing the necessity for 

reheating cold air to satisfy occupant comfort. A detailed technical 

description of the system and system components proposed for 

qualification is required. 

Staff will review the application on a case-by-case basis to 

determine if the system meets the criteria. Manufacturers are 

encouraged to provide additional technical assessment and other 

relevant information beyond the minimum specified in this guidance 

if the applicants believes it will facilitate staff’s determination. 

If the A/C system is determined to be an “improved” system in 

accordance with paragraphs 1 through 4 above and if approved by 

the Executive Officer, the A/C-indirect emission reduction credit will 

be calculated using the following equation: 

A/C-indirect emission reduction credit = 17 – (Compressor 

Displacement in cubic centimeters) x 5 / 100 

Staff will review each application on a case-by-case basis and may 

generate an application template for future use in requesting AC 

system improvement assessment. 

Global Warming Scores for Medium-Duty Passenger Vehicles

(MDPVs)

Currently, MDPVs are certified to California medium-duty vehicle 

(MDV) standards or, under California’s Cleaner Federal Vehicle 

rule, to a federal Tier 2 standard that is deemed more stringent than 
11

California’s based on a comparison of the sums of the respective 

NMOG and NOx useful life standards. Independent of the EP 

labeling regulations, MDPV certified to California MDV standards 

are tested under both the FTP and Highway Fuel Economy test 

procedures; their measured city and highway CO2 values are used 

for determining the CO2-equivalent combined values discussed 

above. 

MDPV certified under California’s Cleaner Federal Vehicle rule are 

subject only to FTP testing from which only the measured city CO2

values are to be reported. Based on 2007 model year certification 

data, MDPV certified to California’s MDV standards have a 

CO2-equivalent combined range from 565 – 729 grams per mile 

CO2-equivalent. Per the EP labeling regulations, any CO2

combined value greater than 520 grams per mile CO2-equivalent 

will receive a global warming score of “1”, the lowest possible. 

Therefore, ARB concludes that all MDPVs will get a global warming 

score of “1.” 

ARB encourages manufacturers of MDPV, especially those MDPV 

to be certified under California’s Cleaner Federal Vehicle rule, to 

submit both CO2 city and CO2 highway values when applying for 

the new EP label. Manufacturers may use the Highway Fuel 

Economy test procedure applicable to California’s MDV – again, 

independent of the EP labeling regulations – to test the official 

MDPV emission data vehicle and submit the measured CO2

highway value for determining the CO2-equivalent combined values 

of the MDPV families certified under California’s Cleaner Federal 

Vehicle rule. If the manufacturer of a MDPV does not submit CO2

highway values with their application, the CO2 city value alone shall 

be used to calculate the CO2-equivalent combined value for 

purposes of determining the global warming score.